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In force Act no. 5-A/2026 in force since 27-07-2026 RTRI fully operational on 01-01-2027 Professionals' deadline: 02-03-2027 Sanctions from 01-06-2027 Sources verified on 3 September 2026

Market

Who is covered, and how urgently

The five categories of Article 13(3) are not labels: each carries its own duties and its own degree of urgency.

Legislative update of 28 July 2026. Act no. 37-A/2026 established the governance of the RTRI, created its Management Board, repealed Article 19 of Act no. 5-A/2026 and set a staggered entry into force. All content on this website has been revised accordingly. See the consolidated calendar.

By category

CategoryUrgencySpecific duties
(a) Social partners and bodies subject to mandatory consultationLowAutomatic registration; Article 7 duties and the 30-day update duty still apply.
(b) Representatives of third-party interestsHighestDeadline of 2 March 2027; disclosure of clients, interests and sectors; record of contractual relationships; conflict-of-interest measures.
(c) Representatives of corporate interestsHighPrior registration before hearings; responsible person; income and public support.
(d) Institutional representatives of collective interestsHighDisclosure of represented interests; publication of the code of conduct.
(e) Other representativesVariableResidual category.

A note on market size

The regime does not create a permanent statutory function comparable to the data protection officer under the GDPR, and therefore imposes no legally required retainer. What it creates is an implementation cycle peaking between the opening of provisional registrations and mid-2027, followed by a considerably lighter maintenance effort. [No consolidated public data exists on the number of entities actually covered; that will only be known once the RTRI operates and the first annual report under Article 16(2) is published.]

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